Submission Description: (doc-less) Out-of-Time Motion to Intervene of Citizens for Pennsylvania's Future under EL25-46-000.

Submission Date:        1/27/2025 7:06:29 PM

Filed Date:             1/28/2025 8:30:00 AM

Dockets
-------
EL25-46-000          Complaint of Commonwealth of Pennsylvania v. PJM Interconnection, L.L.C. under EL25-46.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Citizens for Pennsylvania's Future       oneill@pennfuture.org                                                            

Basis for Intervening:
Basis for Intervening:

Pursuant to Rule 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission, 18 C.F.R. §385.214(b), Citizens for Pennsylvania's Future ("PennFuture") respectfully moves to intervene in the above-captioned proceeding.  

Statement of Interests:

PennFuture is a Pennsylvania-based statewide environmental organization dedicated to leading the transition to a clean energy economy in Pennsylvania and beyond. PennFuture has approximately 1,000 members across the state. PennFuture’s mission is to protect our air, water and land, and to empower citizens to build sustainable communities for future generations. One focus of PennFuture’s work is to halt the buildout of fossil fuel infrastructure in Pennsylvania beyond existing facilities through public outreach and education, regulatory and legislative advocacy, and legal actions. PennFuture also works to advance understanding and recognition of Pennsylvania's Environmental Rights Amendment, contained in Article 1, Section 27 of Pennsylvania's Constitution and to ensure that Commonwealth entities meet their obligations under the Amendment as trustees of Pennsylvania's public natural resources. To promote affordable and clean energy, PennFuture advocates before government entities, including local, state, and federal agencies such as FERC, on issues of market design, policies affecting the clean energy transition, and just and reasonable rates. This proceeding raises issues which are important to the environmental, public health, and affordability interests that PennFuture seeks to advance, particularly with respect to ensuring that market design and policies support and encourage new renewable generation resources.  No other Pennsylvania-based environmental organization is a party to this case.  PennFuture therefore has an interest which may be materially affected by the outcome of this proceeding, and no other party represents its interests. PennFuture therefore satisfies the conditions for intervention both as representatives of interested consumers and because the organization’s participation is in the public interest.

Good cause as to why the time limitation should be waived:

The complaint in this docket was filed on December 30, 2024, and parties continue to intervene and file comments on this docket through the present.  PJM Interconnection, L.L.C. with Governor Josh Shapiro and the Commonwealth of Pennsylvania, which filed the complaint, today filed a joint motion to extend the length of time to respond to the complaint until February 14, 2025. There is no delay as a result of by PennFuture's intervention in this matter. No party represents PennFuture and no party will be prejudiced by any delay and/or by PennFuture's intervention in this matter.

Conclusion:

For the aforementioned reasons, PennFuture respectfully requests that it be granted intervention in this matter.